New Form for Reporting
Suspicious Criminal Activity
The federal regulators, working with federal law
enforcement authorities and the U.S. Treasury Department, have developed a prototype of a
new form for reporting suspected criminal activity to the government. The Suspicious
Activity Report (SAR) will replace the agencies' various criminal referral forms along
with the reporting of suspicious transactions on the Currency Transaction Report (CTR). It
is expected that the use of a single uniform reporting form sent to a single location will
significantly improve the reporting process. The new form also is considerably simpler and
more streamlined than previous criminal referral forms and CTR forms.
To prepare your institution for the new
reporting procedures, we have enclosed an advance copy of the SAR and a draft copy of the
instructions that will accompany the form. The final instructions will be prepared jointly
by the regulators and Treasury's Financial Crimes Enforcement Network (FinCEN). The
regulators and the Treasury expect to issue final reporting rules, to distribute a final
SAR and instructions, and to inaugurate the new reporting system within the next 90 days. Until
the new SAR and reporting system are finalized, you should continue using the FDIC's
current criminal referral forms and instructions.
Also, as noted in a separate mailing, starting
October 1, 1995, institutions can no longer report suspicious currency transactions to the
Treasury on that agency's revised CTR form (see FIL-70-95: Inactive Financial Institution Letters: dated October 12, 1995).
Therefore, banks should use the FDIC's current criminal referral forms to report
suspicious transactions that previously would have been reported by checking the
"suspicious" box on the Treasury's CTR form.
Computer software is being developed to enable
your institution to prepare the new SAR by computer and to file the SAR on magnetic media,
such as a diskette or tape. When completed, the software will be available to your
institution at no charge. If you wish to file SARs using your own computer system instead,
you may obtain the proper electronic format from the Treasury Department by writing or
calling Barbara Rosenberg, SAR Magnetic Media Coordinator, IRS Detroit Computing Center,
985 Michigan Avenue, Detroit, MI 48226 (telephone 313-234-1422). Financial institutions
that currently file CTRs by magnetic tape will automatically receive the specifications
from the IRS Detroit Computing Center.
If you have any questions, please contact the
FDIC's Special Activities Section at 202-898-6750.
Nicholas J. Ketcha Jr.
Attachment (not yet available)
Distribution: FDIC-Supervised Banks (Commercial